1. The General Anti-Abuse Rule and BEPS Action 6 Action 6 of the BEPS initiative has the following three pur - poses: (1) preventing the granting of treaty benefits in inappro - priate circumstances; (2) clarifying that tax treaties are not intended to be used to generate double non-taxation; and

Action 6: Prevent treaty abuse Action 7: Prevent the artificial avoidance of permanent establishment status Action 15: Develop a multilateral instrument Action 14: Make dispute resolution mechanisms more effective 61% 61% 59% 58% 57% 57% 55% 54% 50% 53% 47% 45% 41% 36% 47% 5 Getting to grips with the BEPS Action Plan Open to scrutiny

Additional three prescriptions of the BEPS Action 6 are, adopting anti-abuse China has developed four-tiered standardized approach (master file, local file, 2 Oct 2018 Minimum Standard envisaged under BEPS Action 6 (Prevention of treaty abuse) Three-pronged approach to address treaty shopping. which is the OECD approach proposed in BEPS Action 6. third country resident to invoke a tax treaty benefit, contained in articles 10, 11 and 12 of the tier of the ownership test, that is, even if the ownership test is met, the ta 15 Oct 2018 model convention. Although recommending this “three-pronged approach” to tax treaty shopping, the Final Report of BEPS Action 6 initially introduced, was to implement the expected outcome of BEPS Action 6. reporting system based on the three-tiered approach introduced in the 2016 tax 14 Mar 2014 Action 6 (Prevent Treaty Abuse) describes the work to be undertaken that the following three-pronged approach be used to address treaty 14 Jul 2014 In July 2013 the OECD released its “BEPS Action Plan”, which 15 actions points, one of which is “Action 6 – Prevent Treaty Abuse”.

Beps action 6 three-pronged approach

They've got the three-pronged documentation approach. The Action Plan identifies 15 actions to address BEPS in a comprehensive manner and sets deadlines to implement these actions. The Action Plan recognises that the actions to counter BEPS must be complemented with actions that ensure certainty and predictability for business. Work to improve the effectiveness of the mutual agreement The Action Plan identifies treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. Action 6 The OECD proposal provides a three-pronged approach: Treaty statement re: anti-avoidance rule and treaty shopping opportunities; Specific anti-abuse rule based on Limitation of Benefit The BEPS Action Plan states that “Treaty abuse is one of the most important sources of BEPS concerns”, and then describes Action 6 as recommended the following “three-pronged approach”: 2015-10-05 BEPS Action 14: Make Dispute Resolution Mechanisms More Effective The Organization for Economic Cooperation and Development on December 18, 2014, must be read in the broader context of the intention to introduce a three-pronged approach designed to represent a step change in the resolution of treaty-related disputes through the MAP. Corporate/International tax–Actions1to7and11, 12,14and15. 6. ActionPlan1–DigitalEconomy Action 1: Addressing the tax challenges of the Digital Economy (‘DE’) • No special tax regime has been prescribed.

Many tax havens opted out from several of the Actions, including Action 12 (Disclosure of aggressive tax planning), which was considered onerous by corporations who use BEPS tools. Impact of BEPS Implementation - there was a fairly broad consensus that 1) the Action 1 VAT recommendations are being widely implemented and that they are having a significant impact on tax collection in market jurisdictions; 2) the BEPS changes are impacting business models (particularly Action 7 encouraging a shift towards buy/sell), and that consistency in business model globally was One of those particular actions is BEPS Action 7, which is titled: “Preventing the artificial avoidance of PE status”. The OECD did extensive research on this subject, to which extent they consulted the public twice3, which resulted in a final report on Action 7 in October 2015.4 Previous to the BEPS-project, the OECD BEPS Action 8, 9 and 10 Assure that transfer pricing outcomes are in line with value creation Action 8: Intangibles Page 6 New TP approach for intangibles .

The basic framework of Action 6 is based on a three-pronged approach to be used by countries to release new treaties or to modify existing ones: (1) a clear statement that the Contracting States wish to prevent tax avoidance and creation of opportunities for treaty shopping; (2) a specific anti-abuse rule derived from the U.S. experience (LOB);

standards to reinforced international standards, common approaches to 5 Oct 2015 Although the reports have been billed as the 'final' BEPS reports and shopping (Action Point 6), Country-by-Country Reporting (Action 13), 26 Nov 2015 Session 6 of 8 part OECD BEPS seriesSign up for upcoming live project outcomes Part 6: Anti-abuse Measures under Actions 3, 5, 6 and 12. BEPS is a tax planning strategies that eploits tax and mismatches rules to make profit disappear and shift profits BEPS Action plan -6 Preventing treaty abuse: – BEPS Action plan -13 Three tier standardized approach to transfer pr Action 11 on measuring the BEPS impact (report): the 6 OECD indicators could profit split method and hard to value intangibles, rules for the attribution of average ratio for all other countries, increasing three-fold between 2009 Action 6: Preventing the granting of treaty benefits in inappropriate circumstances . 8.

Impact of BEPS Implementation - there was a fairly broad consensus that 1) the Action 1 VAT recommendations are being widely implemented and that they are having a significant impact on tax collection in market jurisdictions; 2) the BEPS changes are impacting business models (particularly Action 7 encouraging a shift towards buy/sell), and that consistency in business model globally was

Beginning with tax treaty shopping, the Final Report of BEPS Action 6 recommends a “three-pronged approach” comprising the following elements: • a “clear statement” in tax treaties that “the Contracting States, when entering into a treaty, wish to prevent tax avoidance and, in particular, intend to avoid In BEPS Action 6 an approach is recommended to address treaty shopping situations-First, a clear statement that the Contracting States, when entering into a treaty, wish to prevent tax avoidance and, in particular, intend to avoid creating opportunities for treaty shopping will be included in tax treaties. There are 15 BEPS Actions that are currently being considered and worked on by the OECD. For each of the Actions, there are factors to consider such as the timing, impact and potential impact on policy.

Action 6 : Prevent treaty abuse One of the key actions in preventing BEPS is Action 6, Preventing Treaty Abuse which includes combatting treaty shopping. The output is to recommend changes to the Model Tax Convention and recommendations for the design of domestic rules to prevent unintended uses of tax treaties such as group action is more complex and takes time to work out. Such is the case with the OECD’s approach to non-collective investment vehicle funds (non-CIV funds) and their interaction with the BEPS Action 6 on preventing the granting of treaty benefits in inappropriate circumstances. Action 6 refresher Action 6: Preventing the Granting of Treaty benefits in inappropriate circumstances The BEPS Action Plan had identified treaty abuse and treaty shopping as one of the most important sources of BEPS concerns. In order to address these concerns, the task force carried out work to develop model treaty c rules and identify the tax BEPS Project including its four minimum standards (Action 5 on harmful tax practices, Action 6 on treaty abuse, Action 13 on country-by-country reporting and Action 14 on dispute resolution mechanisms).
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The PPT has been also introduced in the Multilateral Instrument (MLI) in force since 1 July 2018. the OECD Base Erosion and Profit Shifting (BEPS) initiative, with special regard for the proposed general anti-abuse rule (GAAR).

The BEPS action plan has 15 actions, covering eleme2015 - nts used in corporate tax avoidance practices and aggressive tax-planning schemes.
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2020-08-17

We do understand and support the idea that Report of the work of the OECD/G20 on the BEPS action 6 ―Preventing the granting of Treaty Benefits in Inappropriate Circumstances‖ where OECD proposed the three-pronged approach on preventing treaty abuse. 5 The first recommendation regards the inclusion in the tax treaties of a BEPS Action 6 INTRODUCTION 1. At the request of the G20, the OECD published its Action Plan on Base Erosion and Profit Shifting (Action Plan)1 in July 2013. The BEPS Action Plan includes 15 actions to address BEPS in a comprehensive manner and sets deadlines to implement these actions. 2.